Austria MOF Clarifies Taxation of Rental Income Under DTA, Protocol With Italy

The Austrian Federal Ministry of Finance April 10 posted online Federal Finance Court Decision No. RV/7102562/2025, clarifying the taxation of rental income under the 1981 DTA and protocol with Italy. The taxpayer, an individual with a residential presence in Austria and Italy, earned rental income in Italy and paid Italian tax on it. The Tax Office treated the rental income under the progression with an exemption method, declining to credit the Italian tax. On appeal, the Federal Finance Court held that: 1) under Article 6 of the DTA, income from immovable property may be taxed in the state where the ...